(a) In this section 'tax advantage' means -
(i) a reduction, avoidance or deferral of any charge or assessment to tax, including any potential or prospective charge or assessment, or
(ii) a refund of or a payment of an amount of tax, or an increase in an amount of tax refundable or otherwise payable to a person, including any potential or prospective amount so refundable or payable.
(b) For the purposes of this section, a series of transactions is not prevented from being a series of transactions in relation to companies by reason only of the fact that one or more of the following is the case -
(i) there is no transaction in the series to which both those companies are parties;
(ii) that parties to any arrangement in pursuance of which the transactions in the series are entered into do not include one or both of those companies;
(iii) there are one or more transactions in the series to which neither of those companies is a party.
(2) Where -
(a) a company within the charge to tax u
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